ENVIRONMENTAL

MONITORING

PLAN

For Applications of 

CHLORPYRIFOS & PERMETHRIN

 

 

PINK BOLLWORM ERADICATION PROGRAM

Arizona, New Mexico, and Texas 

2007 

 

 

United States 

Department of

Agriculture 

Animal and 

Plant Health 

Inspection 

Service 

Plant Protection 

and Quarantine 

Prepared by the 

Environmental 

Compliance Team

Human Health 

& 

Endangered and 

Threatened Species

 March 2007 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 2 

Table of Contents 

HUMAN HEALTH ........................................................................................................................ 4 

Objectives ................................................................................................................................... 4 

Methods....................................................................................................................................... 4 

Contact Information................................................................................................................ 4 

Sensitive Site Inventory .......................................................................................................... 4 

Monitoring with Dye Cards .................................................................................................... 4 

Monitoring Drinking Water .................................................................................................... 6 

Monitoring Vegetation............................................................................................................ 6 

Occupational Health Monitoring ............................................................................................ 6 

Monitoring in Response to Incidents or Complaints .............................................................. 7 

Monitoring for Spills............................................................................................................... 7 

Quality Assurance and Quality Control (QA/QC).................................................................. 8 

ENDANGERED AND THREATENED SPECIES ....................................................................... 8 

Objectives ................................................................................................................................... 8 

Methods....................................................................................................................................... 8 

Inventory................................................................................................................................. 8 

Monitoring for Drift.............................................................................................................. 10 

Monitoring of Run-off and Water Bodies............................................................................. 10 

Monitoring by Observation and Field Notes ........................................................................ 10 

GENERAL MONITORING ISSUES........................................................................................... 10 

Discretionary Monitoring.......................................................................................................... 10 

Documentation.......................................................................................................................... 11 

Shipping of Samples ................................................................................................................. 11 

Supplies..................................................................................................................................... 12 

RESPONSIBILITIES ................................................................................................................... 12 

2007 Operational Procedures/Mitigation Measures Checklist .....................................................A1 

Protection Measures......................................................................................................................B1 

Environmental Monitoring Supplies Checklist.............................................................................C1 

The methods and procedures described in this Environmental Monitoring Plan (EMP) are 

designed to ensure compliance with various statutes including the National Environmental Policy 

Act, the Endangered Species Act, Federal Insecticide Fungicide and Rodenticide Act, as well as 

APHIS policy. Each program organizational unit (e.g. work unit, zone, region, etc.) should 

implement this plan in full during the 2007 pink bollworm eradication season. 

The Southwest Pink Bollworm Eradication Program (Program) is a cooperative endeavor 

involving APHIS, various southwestern states (TX, NM, AZ and CA), the Republic of Mexico, 

and organized cotton grower groups. This EMP is the result of a 2002 Environmental 

Assessment (EA) developed in compliance with the National Environmental Policy Act. The 

monitoring requirements are derived also from consultations with the U.S. Fish and Wildlife 

Service regarding endangered and threatened (E&T) species that might be near program areas. 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 3 

The EMP is designed to validate assumptions made in the EA and to ensure that protective 

measures are effective. This is accomplished by monitoring the environment for residues of 

pesticides used by the Program near areas that might be of human health concern or areas that 

are habitats for E&T species. This Plan also provides guidance for selecting sampling sites, 

collecting environmental samples, and determining sampling frequency. 

Several pink bollworm (PBW) control methods are available for use by the Program. These 

include cultural practices, mating disruption with pheromone, Bt transgenic cotton, sterile moth 

releases, and minimal insecticide applications. Controls that use insecticides are covered by this 

monitoring plan, which include mating disruption and chemical control. 

Mating Disruption 

Aerial, ground, or hand application of pheromone can be made to conventional cotton fields 

(non-transgenic) or to Bt transgenic cotton fields imbedded with conventional cotton. A single 

application of NoMate-PBW® sprayable pheromone, at a rate of 15 gm/ac (1.05 gm [AI]/ac of 

gossyplure), mixed with polybutene sticker (Bio-Tac) at a rate of 5.3 oz/ac and the insecticide 

permethrin at a rate of 0.5 fl oz/ac (0.08 lb. [AI]/ac), is made by air when a field meets the 

treatment threshold. Fields meet the treatment threshold beginning at the six-node growth stage 

(prior to pinhead square) and when trap captures average more than zero but less than one moth 

per trap per night. (Hand applications of pheromone using PB-Rope or PB-Rope*L will not 

require monitoring since pesticides are not used in association with the rope.) 

The insecticide chlorpyrifos, at a rate of 24 fl oz/ac (0.75 lb. [AI]/ac), may be added to the 

pheromone application as a dual aerial treatment, but only if the average trap capture equals or 

exceeds one moth per trap per night. 

Chemical Control 

Aerial or ground applications of the insecticide chlorpyrifos at a rate of 24 fl oz/ac (0.75 lb. 

[AI]/ac), may only be made to prevent economic loss in fields that exhibit larval infestations of 5 

percent or greater. 

Conventional vs. Bt Transgenic Cotton 

The methods listed below to protect human health and E&T species apply to cotton fields that 

may receive pesticides (permethrin or chlorpyrifos) via mating disruption or chemical control. 

This generally applies to conventional cotton fields or Bt transgenic cotton fields imbedded with 

conventional cotton. When “cotton fields” are referred to in the remainder of the monitoring 

plan, this means conventional cotton fields or Bt transgenic cotton fields imbedded with 

conventional cotton. This applies to both the Human Health and the Endangered and Threatened 

Species sections below. Implementation of the monitoring plan in Bt transgenic cotton fields 

without imbedded conventional cotton is not required unless chemical treatments occur in those 

fields. 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 4 

HUMAN HEALTH

OBJECTIVES

Monitoring for potential human exposure is designed to: 

1. Demonstrate the effectiveness of Program operational procedures in excluding or minimizing 

public exposure to Program-applied pesticides; 

2. Collect data which can be used to evaluate whether the assumptions used in the EA and 

Chemicals Risk Assessment are valid estimates of potential exposure of the public to 

Program-applied pesticides by: 

a. monitoring for any aerial spray drift using dye cards to investigate the overall potential 

for exposure; and, 

b. testing crops and water bodies that might be used for human consumption to investigate 

the potential for exposure to pesticides through ingestion; 

3. Ensure that quality assurance and quality control procedures were followed; and, 

4. Respond to Program-related complaints or reports of adverse effects on public health, worker 

safety, environmental quality, or non-target species. 

METHODS

Contact Information 

Note that the APHIS Environmental Monitoring Team is now called the Environmental 

Compliance Team (ECT). This is only a name change as their function with the Program will 

not change. Should any field programs have any changes in their contact information, please 

notify Environmental Compliance of those changes to ensure continued communication. 

Sensitive Site Inventory 

Prior to the start of pesticide treatments, each zone or Program area will make a list of sensitive 

sites that are within 300 feet of cotton fields. Computer models indicate that no pesticide should 

be deposited beyond 300 feet from a treatment area. A site is considered sensitive if it is an area 

of potential human congregation or habitation, or if the site provides a potential route of pesticide 

exposure to humans (i.e. potable water, consumable crops, etc.) Sensitive sites include (but are 

not limited to) residential communities, public buildings, hospitals, medical clinics, day care 

centers, nursing homes, parks, churches, schools, surface water bodies used for human 

consumption, and backyard gardens. Crops that will be consumed unprocessed are considered 

sensitive sites just before and during harvest, if they are within 300 feet of cotton. A list of 

identified sensitive sites including field numbers, locations, and site descriptions will be sent to:

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Rd., Unit 150, Room 5A-04.6 

Riverdale, MD 20737 

or via email to: Robert.M.Baca@aphis.usda.gov 

Monitoring with Dye Cards

Conduct dye card monitoring for drift at all sensitive sites that are within 300 feet of a Programtreated cotton field that requires aerial or ground treatment with chlorpyrifos. Since very few 

fields are expected to receive pesticide treatments, be sure to monitor all treatments within 300 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 5 

feet of a sensitive site. Do not use dye cards to monitor the application of NoMate fiber, whether 

impregnated with permethrin or chlorpyrifos; however, be sure that Program personnel observe 

these applications to ensure proper placement of fiber, with such observations documented in 

Program-maintained databases or on APHIS 2060 Environmental Monitoring Forms. 

Water-sensitive dye cards are used to monitor potential drift of chlorpyrifos reaching a site. 

Before leaving for the field to set-up dye cards, hang a clean dye card from the rear-view mirror 

of the Program vehicle used during sampling (see SOP EM-10, Preparation of Control Samples 

and Collection of Pesticide Samples. If you do not have a copy of this or any other standard 

operating procedure mentioned in this EMP, contact the Environmental Complaince Team (ECT) 

or download it at http://www.aphis.usda.gov/ppq/pdmp/emt/support.html.) This is a control card 

and should remain in place throughout the day. If any of the non-control cards show spots after 

treatments, send the control card to the USDA-APHIS Analytical and Natural Products 

Chemistry Laboratory (ANPCL) for analysis along with an APHIS 2060 form for the control dye 

card. Send this dye card to the laboratory for analysis regardless of whether it is spotted or not. 

The control dye card does not need to be submitted for analysis if all of the non-control cards for 

the day are unspotted, but document the use of the control card on the APHIS 2060 Form that 

you send to the ECT. 

Before treatment begins, place a dye card between the cotton field and the sensitive site, one at 

the edge of the sensitive site, and a third card approximately 30 feet between cards (see SOP 

EM-01, Collection of Dye Card Samples). Draw a diagram (either on the APHIS 2060 form or 

on a separate sheet) of the card positions relative to the field and the sensitive site, indicating the 

distance and direction of the dye cards and sensitive site from the cotton field. Identify and label 

each card individually on the diagram. Place each dye card so that surrounding vegetation does 

not create an obstruction that could interfere with the deposition of chlorpyrifos on the card. It is 

acceptable to place the cards under a tree or other cover if this situation is representative of the 

area between the treatment site and the sensitive site. Two hours after the treatment is 

completed, collect the dye cards. Label each sample according to its location on the diagram. 

DO NOT write on the dye card, but rather on the plastic bag in which the dye card is shipped. 

Writing on the dye card will ruin its analysis for chemical residue. 

Check each dye card for any visible spotting. 

- If none of the dye cards has a visible spot, then record this information on a single APHIS 2060 

form, providing the other information on the sheet as well. Make a note of the total 

number of dye cards without spots. Send the yellow copy of the form and all diagrams, 

maps, etc. to the ECT (Riverdale, MD). These cards do not have to be sent to the 

laboratory for analysis, but should be kept in local program files. Work units, districts, 

and program areas should occasionally submit a set of unspotted dye cards and the 

control dye card used during monitoring for laboratory analysis for quality control 

purposes. 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 6 

-If any of the dye cards in a set has visible spotting, then submit all of the cards (even those 

without spots and including the control dye card) to ANPCL for analysis. Complete a 

separate APHIS 2060 form for each individual dye card (i.e. submit four forms and four 

dye cards to ANPCL.) Fill out all of the information on each APHIS 2060 form, being 

sure to record if that particular dye card was spotted or not. Ship the samples as 

described below. Submit the yellow copy of the APHIS 2060 forms and supporting 

documents to the ECT. 

Monitoring Drinking Water 

Monitor all treatments if surface water bodies used for human consumption are within 300 feet 

of cotton fields. Each work unit, district, or program will make a list of the reservoirs, cisterns, 

or other water bodies used for human consumption that are within 300 feet of cotton fields. 

Provide a description to the ECT of each site and its relation to nearby cotton fields before 

Program treatments begin. If there are no such sites, state this in a brief note to the ECT. 

Collect two water samples from each such water body at least one week before the first Program 

application of pesticides to any nearby field (do not combine these into a single sample). These 

are pre-program samples. Refer to SOP EM-03, Collection of Water Samples. 

When a pesticide treatment is scheduled for a cotton field within 300 feet of a water body that is 

used for human consumption, collect two pre-treatment water samples from different locations at 

the edge of the water (do not combine these into a single sample) within 24 hours of each 

application to the field. These are a separate set of pre-treatment samples from those described 

in the previous paragraph. Collect two post-treatment samples from different locations 2 to 4 

hours after each application. Monitor these water bodies with pre- and post-treatment samples 

during every application of pesticides within 300 feet of the water body. Ship the samples as 

described below. 

Monitoring Vegetation

Fields growing edible commodities, including backyard gardens, within 300 feet of cotton fields 

are considered sensitive sites. Collect vegetation samples whenever a pesticide treatment occurs 

within 300 feet of a site with an edible commodity. Following SOP EM-7, Collection of 

Vegetation Samples, collect pre- and post-treatment vegetation samples from the edges of those 

crops or backyard gardens on the day of treatment. Draw a diagram (on the APHIS 2060 form, 

on a separate sheet, or on the map of the site) of the position relative to the spray zone and the 

sensitive site where the vegetation was collected, indicating the distance and direction of the 

sensitive site from the cotton field. 

Occupational Health Monitoring

Field personnel who might be exposed to malathion should be monitored for serum acetyl 

cholinesterase (AChE) activity. Monitoring should include pre-Program baseline blood samples 

collected before exposure to malathion, followed by samples collected periodically throughout 

the season. At termination of employment or several weeks after all malathion applications have 

ended, a post-Program blood sample should also be collected. 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 7 

Specifics for serum AChE monitoring can be found in the APHIS Safety and Health Manual. 

The manual is available online at www.aphis.usda.gov/mrpbs/ safety_health_wellness.html. 

Blood test results should be reviewed by a licensed health care professional and appropriate 

action taken should a significant inhibition of serum AChE be detected or if clinical signs and 

symptoms of pesticide exposure appear. At the end of the treatment season, results of the serum 

AChE monitoring program should be sent to the ECT in such a way that the anonymity of the 

employees is preserved. 

Monitoring in Response to Incidents or Complaints 

Priority sampling will be conducted to investigate incidents of unknown origin involving 

mortality of non-target species (fish, bees, etc.) or other unintended environmental or human 

health impacts possibly associated with Program-applied chemicals. Program personnel will also 

conduct priority sampling to address a specific public complaint or concern. Information about 

priority samples can be found in SOP EM-09, Priority (Emergency) Sampling. Collect priority 

samples as soon as possible after the complaint, request, or problem is reported. Contact the 

ECT at (301) 734-7592 or 734-8247 to collaborate on a sampling plan, sampling methods, and 

types of samples to collect in order to optimize the investigation. If the incident occurs on a 

weekend, commence your investigation and sampling without delay, and contact the ECT as 

soon as possible on Monday. 

Proper documentation of the incident, investigation, and samples is extremely important. GPS 

maps showing the site, location where samples were collected, the cotton field, and spray lines of 

recent pesticide applications are critical for investigating incidents and should be sent to the 

ECT. Completely fill out all information on a 2060 form for each sample, being sure to check 

the box noting that these are “priority” samples, which will expedite their analysis. Provide an 

incident/complaint report to the ECT, along with any other information that will be helpful in 

resolving the incident (i.e. photos, observations at the site, etc.). The ECT will write a formal 

report documenting the incident and interpreting the residues detected in the samples. Any 

reports that involve the potential exposure of people to Program-applied pesticides should be 

forwarded to the appropriate state agency involved with public health issues (e.g. Texas 

Department of State Health Services, New Mexico Department of Health, etc.) 

Monitoring for Spills 

Pesticide spills (whether from accidents, improper disposal, or aircraft crashes) may be 

monitored, depending on the nature of the incident, contractual arrangements, Program 

guidelines, or local and state procedures. Call ECT personnel immediately so that proper 

procedures and samples may be taken, if necessary. Sampling is usually similar to that described 

above for incidents or complaints, but be aware that you may be sampling materials 

contaminated with concentrated pesticide, and take appropriate safety precautions. 

Samples containing pesticide from spills or accidents can contain enough chemical to ruin 

shipping containers and analytical equipment. Contact ANPCL for information on shipping 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 8 

these samples. Mark each sample and accompanying APHIS 2060 form as a “possible spill 

sample,” so that ANPCL personnel may properly process the sample. 

Quality Assurance and Quality Control (QA/QC) 

A QA/QC checklist can be found on pages A1-2. The checklist describes all of the QA/QC 

measures to be conducted by each program organizational unit to assure adherence to Program 

operating procedures, protection measures, and mitigations. At the end of the treatment 

season, the checklist must be signed by the State Program Manager, State EMS, or other 

appropriate personnel indicating that all of the QA/QC activities were followed. Record any 

deviations along with an explanation and any corrective actions taken. Attach this information to 

the checklist. After the conclusion of Program operations for the season, promptly submit the 

signed checklist to the ECT. Sampling of neat chemical (concentrated, in the shipping container) 

is not required for QA/QC purposes, since the chemicals are obtained on an “as needed” basis 

from commercial sources and are not stored in a manner which might result in degradation of the 

chemical. 

ENDANGERED AND THREATENED SPECIES

OBJECTIVES

Monitoring near endangered and threatened (E&T) species habitat is designed to provide data 

which can be used to evaluate the effectiveness of protection measures established for those 

species. Each year, zones, districts, or programs must reassess the presence of E&T species and 

their habitats. If a species is found in or near a Program area, and it has not been addressed in 

this document or the current Biological Assessment, contact the ECT immediately at (301) 734-

8247. Take action to assure that Program operations do not disturb the species or habitat in 

question until further guidance is obtained from the U.S. Fish and Wildlife Service. This 

monitoring plan lists all protected and proposed species known to occur in AZ, NM, and TX, as 

of the writing of this document and their associated protection measures on pages B1-8. The 

U.S. Fish and Wildlife Service has not issued its concurrence with the protection measures yet. 

But no changes are expected and the Program should use the protection measures as listed below. 

If any changes occur, the Program will be notified so that the correct protection measure can be 

implemented. If any of the listed species is found near Program cotton, the protection measure 

for that species must be implemented. 

METHODS

Inventory 

A complete inventory of all E&T sites near Program cotton fields is needed to fully evaluate the 

Program’s ability to protect E&T species. Before the first treatments are made, each work unit, 

district, and program staff shall contact the local FWS office concerning listed E&T species and 

the location of their habitats in all counties that may receive treatments during 2007. Note that 

proposed species are also shown on pages B1-8 for information purposes only. No monitoring is 

required with these proposed species, but if they become listed as threatened or endangered, is it 

likely that the proposed protection measures will come into effect. If proposed species are in an 

area under your jurisdiction, we strongly advise that you implement the corresponding protection 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 9 

measures. Please note that this document does not consider state protected species (some of 

which may not be federally protected), and we suggest that you contact the state Departments of 

Wildlife or other appropriate agencies regarding such species that might exist near cotton fields. 

Even if you do not expect to treat any fields this year with pesticides, is it recommended that you 

contact FWS for the location of protected species that may be near cotton fields. Should any 

fields require treatments, such treatments cannot begin until protected species locations are 

known. Since it can take some time for FWS to respond with the location of the protected 

species, it is in the Program’s best interest to identify those locations ahead of time rather than 

potentially delay possible unexpected treatments. 

Prior to the start of treatments, contact the local FWS field office for a list of endangered and 

threatened species, species proposed for listing, and critical habitat designations in the counties 

under your Program jurisdiction. Then compare this list to the species listed below on pages B1-

8. If a protected species is listed within a Program area and has a protection measure on pages 

B1-8, contact the FWS field office again to determine the location of that species and its relation 

to Program cotton fields. If any portion of a cotton field falls within the listed distance for a 

protection measure, implement that measure with guidance provided by the ECT. Document this 

process and report it to the ECT, including the names and affiliations of those contacted, a list of 

E&T species in Program counties, a list of fields by field number where potential treatments 

would require protection measures for E&T species, and any other details regarding specific 

protection measures to be implemented. 

Page B-9 is the “Endangered and Threatened Species Site Reporting Form.” This form is to be 

used by each work unit, district, or program to document the presence and location of each E&T 

species or habitat as part of the reporting described above. Use additional paper if needed. The 

list should include any proposed species found near cotton and whether or not the protection 

measures for them will be implemented. If an organizational unit has protected species in its 

jurisdiction that do not require the implementation of a protection measure (i.e. they are very far 

away from cotton fields), those species should also be listed on the form with a note in the 

comments section stating that the species are beyond the given limits requiring protection 

measures. The completed form must be returned to the ECT before treatments begin for the 

year. Send the completed form to Dr. Robert Baca at the address listed on page B-9. 

Protection measures include buffer zones, observational monitoring, dye card monitoring, water 

monitoring, and run-off monitoring. If a protected species is located near Program-treated 

cotton, the listed protection measures must be fully implemented. Note that many species are 

excluded from monitoring since it was determined that the program will have no effect on the 

species. These species are listed on pages B1-8 with an “NE” (for “no effect”) under the 

protection measures. 

Several protection measures do not require monitoring. For example, the measure for the 

Mexican long-nosed bat states that “To protect the Mexican long-nosed bat from aerial and 

ground application of permethrin and chlorpyrifos, a 60 foot ground buffer and a 300 foot aerial 
2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 10 

buffer will be used at the edge of any entrance of an occupied roost or potential roost site of the 

Mexican long-nosed bat.” There are no monitoring requirements for this species, but the buffer 

zones must be implemented and documented in writing on the “Endangered and Threatened 

Species Site Reporting Form.” 

When monitoring is required, the type of monitoring is specified in the protection measures. The 

distance from a cotton field to a protected habitat that requires monitoring is listed in the 

protection measures. For example, if a protection measure states, “No use within 60 feet of 

identified aquatic habitat. Monitor for run-off,” then any cotton field that might receive Program 

treatments that extends up to or within 60 feet of the habitat in question would require run-off 

monitoring. In this example, if any portion of a cotton field extended into the 60-foot notreatment buffer area, monitoring would be required even though no pesticide would be applied 

within the buffer area. 

Monitoring for Drift 

When a protection measure notes to “Monitor for drift,” dye cards are to be used. Dye cards 

should be placed at the edge of habitat of the species. Do not place the dye cards next to the 

cotton field, but rather adjacent to the protected habitat. Use the methods described in the 

Human Health section above and in SOP EM-01, Collection of Dye Card Samples. 

Monitoring of Run-off and Water Bodies 

No sampling of aquatic locations is required at this time. Should updated protection measures 

require aquatic sampling, instructions and training will be provided to the Program. 

Monitoring by Observation and Field Notes 

Note-taking is required for most monitoring. Most often a sentence regarding general procedure 

is sufficient (for example: “nothing unusual noted during or after spray”). In addition, note the 

time of treatment, and any wildlife activity in or around the field at E&T species sites. Refer to 

SOP EM-12 Using a Field Log Book. Photocopies of field log books should be submitted, or the 

notes can be made directly into the “remarks” section of the APHIS 2060 form submitted to the 

ECT. In the case of monitoring eagle nests, see note-taking recommendations in SOP EM-18 

Observing Bald Eagles at Nest Sites. Documented observations are required as per the 

protection measures, and these notes should be submitted to the ECT. 

GENERAL MONITORING ISSUES

DISCRETIONARY MONITORING

At the discretion of program managers or environmental monitoring staff, additional monitoring 

samples can be collected. Although the monitoring outlined in this plan should be adequate to 

meet the objectives noted above, the program manager may decide that additional sampling may 

be necessary around particular sensitive sites. Examples might include sites that are highly 

visible to the public or are politically sensitive sites where environmental monitoring might help 

prevent future conflicts, and sites of proposed protected species. 
To ensure that sampling equipment is not accidentally exposed to pesticides, work units or 

program areas may periodically submit an unused dye card, distilled/deionized water in Program 

containers, or gauze wipes of sampling equipment in storage for analysis for permethrin or 

chlorpyrifos. Individual APHIS 2060 forms must be included, as with any sample submitted for 

analysis. 

To independently verify the analyses of the USDA laboratory, work units or program areas may 

periodically follow procedures for taking, documenting, and submitting split samples for 

analysis. Split sampling involves taking a single sample and dividing it in half, with each half 

analyzed by a different laboratory. If a work unit or program area chooses to take split samples 

of any type, they must first contact the ECT at (301) 734-8247 to discuss the precise procedures 

required for taking proper split samples. 

DOCUMENTATION

A clear diagram of the sensitive site and where each sample is collected will be drawn either on a 

Geographic Information System (GIS) map, on a separate piece of paper, or on the 2060 forms 

associated with the samples. If a series of samples is collected from the same site, the map and 

diagram need only be submitted once, as long as the site and each sample are clearly indicated on 

the map and in the appropriate sections of each APHIS 2060 form. 

For each sample collected, a separate APHIS 2060 form must be completed. This is especially 

true for dye cards, where each dye card must be submitted using a separate 2060 form. 

Instructions for completing the 2060 forms may be found on the back of each form. For each 

sample: the blue copy of the APHIS 2060 form should be submitted to ANPCL physically 

accompanying the sample; the white copy of the form submitted to ANPCL in the sample 

shipping container but separate from the sample; and the yellow copy of the form (and any maps, 

photos, etc.) submitted to the ECT. The APHIS 2060 form for any samples that are not sent to 

the laboratory for analysis (i.e. unspotted dye cards) should be sent only to the ECT. Pink copies 

of the form are retained by the staff that collected the sample. 

Samples must be properly identified as routine or priority. An incorrect identification regarding 

the nature of the sample creates confusion in those who must interpret the data and delays the 

processing of samples that are incorrectly marked. Samples should be checked “priority” only in 

instances where a fast turnaround of samples is required. This applies to all complaint 

investigations, spill incidents, potential human health issues, and other samples considered to be 

of very high importance. Otherwise, the sample should be marked as “routine.” 

SHIPPING OF SAMPLES

All samples, including dye cards, must be shipped using some form of overnight delivery. See 

SOP EM-17, Packaging and Shipping of Samples for details. This applies to all samples, 

whether they are priority or routine. Samples must not be shipped using USPS Priority Mail or 

standard ground service with other carriers. Overnight delivery allows the sample to stay frozen 

or at least cold. Shipping any other way will take no less than 2-3 days, causing the ice and 

sample to melt, which can ruin the sample. 

2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 11 
With the exception of neat (pure) chemical, all samples must be frozen, shipped in a cooler box 

(not a regular cardboard box), and kept frozen during shipment. To keep samples cold, the use 

of dry ice is recommended since it does not turn to liquid when warmed and will therefore not 

ruin any forms or samples. However, if water samples are shipped, do not use dry ice, since it 

will cause the sample containers to crack or break. Since dry ice may not be available in all 

areas, regular ice can be used for shipping any samples, but only if the ice is placed in a separate 

sealed container. Either use “blue ice” containers (the reusable plastic containers with the blue 

liquid/gel inside) or contained regular ice (that is, seal the ice in zip-loc bags). Unsealed ice will 

melt and leak during shipment and cause great concern when received at the laboratory. 

SUPPLIES

Supplies for monitoring are ordered through the APHIS Analytical and Natural Products 

Chemistry Laboratory (ANPCL). A checklist for ordering supplies is located on pages C1-2. 

ANPCL prefers that supply orders be faxed to them using the numbers listed on the checklist 

rather then leaving a voice message for orders. 

RESPONSIBILITIES

USDA-APHIS Environmental Compliance Team 

In addition to preparing the EMP, ECT personnel in Riverdale, MD, will: 

1. Review and interpret field data and pesticide residue data as they arrive from the sample 

collectors and the laboratory. Contact the sample collector for clarification as soon as 

possible if any field data is incomplete or unclear. Notify the Program Director and 

Manager immediately if any residue data indicates the possibility of excessive exposure 

to pesticide. 

2. Provide training, clarification, and interpretation on how to implement the Environmental 

Monitoring Plan. 

3. Submit a comprehensive interpretive report to the Program Director and the National 

Coordinator, within 60 working days of receiving all of the Program’s field data and the 

results of all residue analyses for environmental monitoring. Following review of the 

information, the ECT will provide a copy of the annual report to the Environmental 

Protection Agency and U.S. Fish & Wildlife Service. 

USDA-APHIS Analytical and Natural Products Chemistry Laboratory 

Personnel at the ANPCL in Gulfport, MS, will: 

1. Prepare and ship sampling containers and other material required for collection, stabilization, 

and shipping of environmental monitoring samples. 

2. Provide training on methods for collecting, handling, preserving, and shipping samples. 

3. Respond to requests for additional information by field personnel when special sampling 

requirements occur. 

4. Analyze monitoring samples according to standard operating procedures for malathion. 

5. Complete analyses and report results on the following schedule: 

2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 12 
a. Within 23 working days after receipt, complete analyses of all routine samples and 

send results to the ECT. 

b. Within 5 working days after receipt, complete analyses of all priority/emergency 

samples and send results to the ECT. 

6. Contact ECT if the projected completion schedules need to be extended due to sample load or 

instrument problems on site. 

7. Forward copies of all environmental monitoring forms and any attached documentation to the 

ECT each week via overnight mail. 

Program/Foundation/Organization Employees, PPQ Field Service Personnel or 

Cooperators, Under the Direction of the Program Director 

Personnel in work unit, district, and program areas will: 

1. Ensure that sufficient resources from the Program are allocated for completing the monitoring 

activities described in the Environmental Monitoring Plan (EMP). 

2. Coordinate with Federal and local wildlife officials to identify E&T species and habitats near 

or within areas that may be affected by Program activities, inform the ECT of these 

species and locations, and implement the required protection measures. 

3. Identify all sensitive sites near cotton fields as described in the EMP. 

4. Select sufficient monitoring sites for the collection of samples. Follow instructions in this 

EMP and referenced SOPs to develop a compliant local work plan for sample collection 

and documentation, including: 

a. Collection of the type and number of environmental samples recommended in the EMP. 

b. Completion of a separate APHIS 2060 form for each sample that is collected. 

c. Providing all the information necessary (as described above) to document the samples. 

Following each treatment, send all supporting documentation, including a copy of the 

appropriate APHIS 2060 forms to the ECT. Send all samples and appropriate APHIS 

2060 forms to ANPCL. Ship all samples and supporting documentation as soon as 

possible after collection. 

d. Notification of ANPCL prior to shipping any priority, spill, or unusual (i.e. other than 

water, dye card, soil, or vegetation) samples. 

2007 Environmental Monitoring Plan, Pink Bollworm Eradication Program 13 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-1 

2007 Operational Procedures/Mitigation Measures Checklist 

Pink Boll Worm Eradication Program 

(Modify as needed for each work unit, district, or program area) 

______ Retain a copy of all the pesticide certifications for Program personnel who are applying or supervising the 

application of pesticides. Certificates were reviewed annually. 

______ Contractors’ pesticide application certificates were available and recorded prior to the initial pesticide 

application. 

______ Copies of all APHIS Form 2060’s submitted to the USDA analytical laboratory were retained at the work 

unit, district, or program area as documentation of the environmental monitoring program. 

______ A printout, or electronic file, of all trapped cotton fields, and the dates traps were checked and fields were 

treated, was retained as documentation for meeting all trapping and treatment criteria. 

______Operational Procedures and Recommended Mitigation Measures as defined in the Southwest Pink 

Bollworm Eradication Program - 2002 Environmental Assessment (see below, pages A1-7), were reviewed 

with all appropriate Program personnel and copies were distributed as appropriate. Measures for chemicals 

not used by the Program may be ignored. 

______ Sensitive areas as defined in Table 2-1 in the Environmental Impact Statement (attached) were identified in 

each field unit. Appropriate Program supervisory personnel are familiar with all sites and have applied 

appropriate protective measures to avoid negative impact. Program personnel have reviewed these areas 

with field unit supervisors each spring prior to pesticide application, assessed the sites for environmental 

monitoring sampling, and provided appropriate seasonal review. 

______ The following was issued to each employee as appropriate and serve as instructions for operational 

procedures: 

 _____ a. Trapper Guide and Trapper Agreement _____ d. Airplane Observer Duties 

 _____ b. Mist-Blower Operational Guide _____ e. Airport Recorder Duties 

 _____ c. Hi-Boy Operational Guide _____ f. BWEP Safety Manual 

 

______ Mist-blower and hi-boy operator training was conducted. Each employee signed a statement that they have 

received appropriate operational and safety training. This statement is retained in their personnel folder. 

______ Each employee involved with pesticide use was tested for blood acetyl cholinesterase levels as necessary. 

Copies of all cholinesterase tests were retained in each employee's folder. 

______ Two-way radio contact was maintained to allow communication between pilots and ground observers, to 

enhance safety and the effectiveness of each treatment. 

______ Wind and weather conditions were recorded to document meteorological conditions during treatments. 

______ Airplane check-in procedures certified nozzle type, size and number, spray system pressure, nozzle 

orientation, etc. This check-in list and subsequent seasonal inspections were retained in the work unit, 

district, or program area office for each aircraft used in the Program. 

______ Correct operational and safety procedures for mist-blowers and hi-boys were monitored weekly by Program 

supervisory personnel and documented in the mist-blower log. Program supervisory personnel checked at 

least one mist-blower operator or hi-boy operator each week during the control season. 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-2 

______ A minimum of one aerial application operation was monitored by Program supervisory personnel each 

week for each contractor. This monitoring procedure was noted on flight records. 

______ Pesticide labels were carried in the vehicle of all persons involved with application, i.e. mist-blower 

operators, hi-boy operators, airplane observers, field supervisors, and Program supervisory personnel. 

______ Dye cards were labeled as to field numbers, date, and time of application. These cards were inspected by 

Program supervisory personnel and retained in the work unit or program area office or sent to the USDA 

laboratory for analysis as described in the Environmental Monitoring Plan. 

______ Initiation of Program operations was preceded by a notification to the following agencies: 

 _____ a. State Department of Agriculture or similar agency; 

 _____ b. State Conservation and National Resources Agency or similar agency; 

 _____ c. State Forestry Commission or similar agency; 

 _____ d. State Department of the Environment or similar agency; and 

 _____ e. Local governmental and county agencies (provide listings below). 

 Included in the notification letters was a request for assistance in identification of potential sensitive sites 

near cotton fields. 

______ A safety equipment check-off list was signed by each employee involved in pesticide application. This was 

retained in the employee’s personnel folder. 

______ Safety procedures dealing with exposure to pesticides were inserted into the Program safety manual and 

made available to all employees handling pesticides. 

______ Empty pesticide containers were returned to the distributor. 

______ All complaints were documented, thoroughly investigated, and resolved. Those involving alleged pesticide 

misuse were referred to the appropriate state authority. Copies of complaints and actions taken were 

maintained on file. Copies of any state investigative reports were retained in the work unit or program area 

and copies submitted to the USDA-APHIS Environmental Compliance Team. 

______ Local contacts with U.S. Fish and Wildlife Service concerning endangered and threatened species habitat 

and mitigation measures were documented. 

The above procedures and measures were performed in the __________________________________ work unit, 

district, or program area during the 2007 season. Any minor deviations in such were corrected when observed. 

Deviations and/or pesticide incidents and corrective actions taken have been documented and are described as 

follows: 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________ ____________________________ 

Signature Date
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-3 

NOTE: The following two pages are copied from the 2002 Environmental Assessment (EA) section called “Additional 

Protective Measures.” These are the most current measures that have undergone the National Environmental Policy Act 

(NEPA) review process. The measures are “in addition” to those listed on pages A4-7 below, although several are 

redundant so that the EA would be more comprehensive in scope than the EIS that it references. 

Southwest Pink Bollworm Eradication Program 

Environmental Assessment - April 2002

Additional Protective Measures 

Comprehensive routine operational procedures and mitigation measures that have been followed in 

previous cotton control programs (USDA, APHIS - see pages A4-7 below) will be adhered to in this 

program. The following additional protective measures, recommended for the proposed Pink 

Bollworm Eradication Program, may further reduce the potential for adverse environmental effects 

from this program. 

Pesticide Applications 

1. Program personnel overseeing applications of organophosphate and synthetic pyrethroid 

(chlorpyrifos and permethrin) pesticides are required to wear protective clothing or remain 

inside a closed vehicle with re-circulating air, depending on the circumstances of the 

application. 

2. Unprotected workers will be advised of the respective reentry periods following treatment. 

3. Program personnel shall immediately cease spraying operations if members of the public are 

observed within 100 feet of a cotton field being sprayed with chlorpyrifos or permethrin. 

4. Aerial applications will not be made to sensitive areas (residences, public buildings, water bodies, 

hospitals, primary and secondary schools, day care centers, in-patient clinics, nursing homes, 

parks, churches); program treatments will be applied only to cotton fields. 

5. Aerial applications will be made at a height of 5-12 feet above the cotton canopy, unless precluded 

by obstructions. 

6. Program personnel will familiarize aerial applicators with applicable operational procedures, 

mitigation measures, and protection measures. 

7. Before initiating operations, APHIS will obtain concurrence from the U.S. Department of the 

Interior's Fish and Wildlife Service on protection measures that are required for endangered and 

threatened species, or their critical habitats. 

8. Program personnel will be present during all treatments near sensitive areas; they will use dye cards 

along field edges to detect off-site drift of pesticides. 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-4 

9. The program will report any incident of pesticide poisoning to the local Department of Health; 

information about the validity and probable cause will be used to develop additional protective 

measures, as necessary. 

Notification Procedures 

1. Program personnel will provide advance written or telephonic notification of the approximate times 

and dates of treatments to area residents who reside within 3 miles of treatments and who 

formally request (providing their name, address, and telephone number) special notification. 

2. Program personnel will publish public notices of the availability of the environmental assessment 

(EA) for this program in local newspapers; copies of the EA will be provided to local libraries. 

3. Growers participating in the program will be notified of treatment dates so that they may provide 

timely and appropriate notice of treatments and protective measures to persons in their employ 

or residing on properties who could be exposed to chemical pesticides. 

4. Residents who are registered with the local state department of agriculture as having multiple 

chemical sensitivity will be notified in writing or by telephone of the time of any program 

treatments to be made within 3 miles of their residence. 

5. Before beginning treatment with chlorpyrifos or permethrin, program personnel shall notify all 

registered apiarists in or near the treatment area of the date and the approximate time of 

treatment. 

 

Operational Procedures and Mitigation Measures 

National Boll Weevil Cooperative Control Program 

NOTE: These operational procedures and mitigation measures have been adopted for, and are an integral part of, the 

cooperative Boll Weevil Eradication Program. They were printed originally in the programmatic Environmental Impact 

Statement of 1991, and were revised as necessary in 2005. 

Table 2-1 Operational Procedures

All Methods of Control 

1. All applicable Federal, State, and local environmental laws and regulations will be followed during 

boll weevil control operations. 

2. Sensitive areas (water bodies; parks; and occupied dwellings, such as homes, schools, churches, 

hospitals, and recreation areas) that may be adjacent to cotton fields will be identified. The 

program will be adjusted accordingly to ensure that these areas are not negatively affected. 

3. Environmental monitoring of the program will be in accordance with the current environmental 

monitoring plan. 

4. All cotton fields will be trapped. During the initial diapause year of the program, all fields will be 

treated from “ten percent cracked boll” until there is no hostable material remaining. In 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-5 

subsequent years, only hostable fields from which boll weevils have been caught will be 

treated. 

5. All program personnel involved in chemical applications will be instructed on the safe use of 

malathion, the safe use of equipment, and on operational procedures. Field supervisors will 

train Field Technicians, mist blower operators and high-clearance sprayer operators on 

operational procedures, and monitor their conduct during working hours. 

Aerial Applications 

1. All materials will be applied in strict accordance with EPA- and State-approved label instructions. 

2. Aircraft, spray equipment, and pilots that do not meet all contract requirements will not be allowed 

to operate. 

3. All USDA, APHIS, Plant Protection and Quarantine employees who plan, supervise, recommend or 

perform pesticide treatments must be certified under the APHIS pesticide certification plan. 

They are also required to meet any additional requirements of the State where they perform 

duties involving pesticide use. All Foundation personnel involved in pesticide application must 

maintain State pesticide applicator certification as required by state law. 

4. Upon notification by program personnel, growers will advise workers of the re-entry period 

following treatment. 

5. Two-way radios or aircraft radio frequencies will be provided to program personnel who direct, 

coordinate, or observe pesticide applications, to facilitate communication with the pilot. 

6. All APHIS field personnel will have baseline cholinesterase tests before the first application and 

each spring and fall thereafter. It is recommended that contract, State, and private personnel 

also participate in this testing program. 

7. Only certified aerial applicators who have been familiarized with local conditions will be used by 

the program. 

8. To minimize drift and volatilization, applications will not be made when any of the following 

conditions exist in the treatment area: wind velocity exceeds 10 miles per hour (or less if 

required by State law); prevailing wind is blowing toward a nearby residence or other sensitive 

site; rain is falling or is imminent; fog is present, or air is turbulent enough to seriously affect 

the normal spray pattern; or temperature inversions exist that could lead to offsite movement 

of applied material. 

9. Nozzle types and sizes, spray system pressure, and nozzle orientation will be specified in the 

program’s aerial application contract or as otherwise directed by program personnel. 

Ground Applications 

1. Mist Blowers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with 

certified applicators. 

 • Units will be operated from closed truck cabs with operators using re-circulated air. 

2. High-Clearance Sprayers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with 

certified applicators. 

 • Spray operations will be conducted from closed cabs using re-circulated air. 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-6 

Table 2-2. Recommended Mitigation Measures 

All required State and local authorities will be notified upon initiation of the program. The notification 

will advise State and local authorities of the need for any assistance in identifying sensitive areas in 

proposed treatment areas. 

Protection of Workers 

All program personnel will be instructed on emergency procedures to follow in the event of insecticide 

exposure. Equipment necessary for immediate washing procedures must be available for application 

personnel. 

Aerial Applications 

1. Pilots, loaders, and other personnel handling insecticides will be advised to wear safety equipment 

and protective clothing. 

2. Program personnel observing applications of malathion are required to wear protective clothing or 

remain inside a closed vehicle with re-circulating air, depending on the circumstances of the 

application. 

3. Application operations will be postponed in fields in which people are working. These fields will 

not be treated when workers are present. 

4. GPS systems are required on all contract aircraft. They will be used for pilot guidance, mapping 

fields to be treated, and assistance in locating fields and marking swaths. 

Ground Applications 

1. Mist Blowers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with 

certified applicators. 

 • Operators will wear appropriate safety equipment when loading or servicing the unit, and will 

be specially trained by program personnel. 

 • Mist blower units will be operated from closed truck cabs with operators using re-circulated 

air. 

2. High-Clearance Sprayers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with 

certified applicators. 

 • Operators will wear appropriate safety equipment and protective clothing when loading or 

servicing the unit. 

 • High-clearance sprayers will be operated from closed cabs with operators using re-circulated 

air. 

Pesticide Handling Precautions 

1. Insecticides will be delivered and stores in sealed totes (mini-bulk tanks) or drums and then pumped 

directly into the spraying equipment. 

2. All insecticides will be stored in accordance with Federal, State, and local regulations and label 

instructions. 
2007 Operational Procedures & Mitigation Measures, Pink Bollworm Eradication Program A-7 

3. All loading and unloading of insecticides will be within a containment area where an accidental 

spill will not contaminate a stream or other body of water. 

4. In the event of an accidental spill, procedures set forth in the PPQ Treatment Manual, chapter 7, 

pages 7-3-1 through 7-3-18, entitled, “Guidelines for Managing Pesticide Spills” will be 

followed. 

5. All empty insecticide totes (mini-bulk tanks) and drums will be returned to the distributor for 

reconditioning. 

Protection of the Public 

1. Application aircraft shall avoid direct spraying of residences, garden plots and adjacent crops at all 

times. 

2. Program personnel shall immediately cease spraying operations if members of the public are 

observed within 100 feet of a cotton field being sprayed with malathion. 

Protection of Bees 

Before beginning treatment with malathion, program personnel shall notify all registered apiarists in or 

near the treatment area of the date and approximate time of chemical treatment. 

Protection of Wildlife 

1. All control operations will be conducted with appropriate concern for their potential impact on 

endangered, threatened, and proposed species identified in this document. 

APHIS has prepared a biological assessment for federally listed endangered, threatened and proposed 

species found within all U.S. cotton-producing counties from species information provided by 

the U.S. Department of the Interior, Fish and Wildlife Service (FWS) and State wildlife 

agencies. 

Adequate protection measures are developed for federally listed endangered, threatened and proposed 

species through the Endangered Species Act, section 7, formal and informal consultations with 

FWS. Specific biological and distributional data for species is gathered in discussions between 

APHIS, Plant Protection and Quarantine, local FWS offices, State wildlife agencies and the 

Foundation before operations begin. 

Species and habitats protected by State laws are addressed in site-specific assessments as needed. 

2. Oil-sensitive dye cards are used to regularly monitor application efficacy. Spray deposition in the 

target area and droplet size are critical concerns.
Protection measures for endangered & threatened species – 2007 B-1 

Protection Measures 

for Endangered, Threatened, and Proposed Species as part of the 

2007 Pink Bollworm Eradication Program in New Mexico, Arizona, and Texas 

CHLORPYRIFOS AND PERMETHRIN 

KEY

STATUS: E=Endangered, T=Threatened, CH=Critical Habitat, PE=Proposed Endangered, PT=Proposed Threatened, PCH=Proposed 

Critical Habitat, EXPN=Experimental Population. 

PROTECTION MEASURES: NE=APHIS determines that the Pink Bollworm Program will have No Effect on populations of this 

listed species. 

Changes from last year’s Program are highlighted in gray.

 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

MAMMALS 

Bat, 

Mexican 

long-nosed 

Leptonycteris 

nivalis E 

To protect the Mexican long-nosed bat from aerial and ground application of 

permethrin and chlorpyrifos, a 60-foot ground buffer and a 300-foot aerial buffer will 

be used at the edge of any entrance of an occupied roost or potential roost site of the 

Mexican long-nosed bat. 

Bat, lesser 

long-nosed 

Leptonycteris 

curasoae 

(=sanborni) 

yerbabuenae 

E 

To protect the lesser long-nosed bat from aerial and ground application of permethrin 

and chlorpyrifos, a 60-foot ground buffer and a 300-foot aerial buffer will be used at 

the edge of any entrance of an occupied roost or potential roost site of the lesser longnosed bat. 

Ferret, 

black-footed Mustela nigripes E, EXPN NE – Excluded by habitat. 

Jaguar Panthera onca E 

To protect the jaguar from aerial and ground application of permethrin and 

chlorpyrifos, the program will monitor insecticide drift at habitat edge if field is 

within 300 feet of known occupied habitat. Known occupied habitat is defined as 

areas where jaguars have been observed within the last year. 

Ocelot Leopardus 

(=Felis) pardalis E 

To protect the ocelot from aerial and ground application of permethrin and 

chlorpyrifos, the program will monitor insecticide drift at habitat edge if field is 

within 300 feet of known occupied habitat. Known occupied habitat is defined as 

areas where ocelots have been observed within the last year. 

Pronghorn, 

Sonoran 

Antilocapra 

americana 

sonoriensis 

E NE – Excluded by habitat. 

Squirrel, 

Mount 

Graham red 

Tamiasciurus 

hudsonicus 

grahamensis 

E,CH NE – Excluded by habitat 

Vole, 

Hualapai 

Mexican 

Microtus 

mexicanus 

hualpaiensis 

E NE – Excluded by habitat 

Wolf, gray Canis lupus E, CH, 

EXPN NE – Excluded by habitat. 

BIRDS 

Bobwhite, 

masked 

Colinus 

virginianus E To protect the masked bobwhite, the Service should be consulted before implementation of a pesticide program adjacent to the Buenos Aires National Wildlife 
Protection measures for endangered & threatened species – 2007 B-2 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

ridgwayi Refuge in Pima Co., AZ. 

Condor, 

California 

Gymnogyps 

californianus AZ=EXPN NE – Excluded. Experimental nonessential pop. 

Crane, 

whooping Grus americana E,CH, EXPN 

To protect whooping cranes from aerial and ground application of permethrin and 

chlorpyrifos, the program will check fields for cranes before application. Fields with 

cranes must not be sprayed until cranes have left the field (without inducement). 

Eagle, bald Haliaeetus 

leucocephalus T 

To protect the bald eagle from aerial and ground application of permethrin and 

chlorpyrifos, the following measures will be applied. Permethrin: No aerial use 

within 1⁄4 mile from currently occupied nests. Chlorpyrifos: No aerial or ground use 

within 1⁄2 mile from currently occupied nests. Aerial pesticide applications should be 

made in swaths parallel to a nest and its aerial buffer zone. If aerial flight over a nest 

is necessary, an elevation of 500 feet should be maintained over the nest. To protect 

the aquatic food sources of the bald eagle, an 80-foot ground buffer and 500-foot 

aerial buffer for both permethrin and chlorpyrifos will be used to protect fish in small 

water bodies for up to 1 mile both up- and downstream from an active eagle nest. 

Falcon, 

northern 

aplomado 

Falco femoralis 

septentrionalis E 

To protect the northern aplomado falcon and its prey from aerial and ground 

application of permethrin and chlorpyrifos, the following measures will be applied. 

Permethrin: No aerial or ground applications within 1⁄4 mile of a currently occupied 

nest. Chlorpyrifos: No aerial or ground applications within 1⁄2 mile of known 

occupied habitat. Aerial pesticide applications should be made in swaths parallel to a 

falcon nest and its aerial buffer zone. Applicators should watch for falcons in the area 

of application and not make any pesticide application until after falcons have left. 

Flycatcher, 

southwestern 

willow 

Empidonax 

traillii extimus E,CH 

To protect the southwestern willow flycatcher and its prey from aerial and ground 

applications of permethrin and chlorpyrifos, the following protective measures will be 

used. Permethrin: No ground use within 30 feet and no aerial use within 150 feet of 

species habitat. Chlorpyrifos: No ground use within 60 feet or aerial use within 300 

feet of species habitat. 

Owl, Cactus 

ferruginous 

pygmyGlaucidium 

brasilianum 

cactorum 

Delisted None – delisted taxon 

Owl, 

Mexican 

spotted 

Strix 

occidentalis 

lucida 

T,CH NE – Excluded by habitat 

Pelican, 

brown 

Pelecanus 

occidentalis E NE – Excluded by habitat 

Rail, Yuma 

clapper 

Rallus 

longirostris 

yumanensis 

E 

To protect the Yuma clapper rail and its prey from aerial and ground applications of 

permethrin and chlorpyrifos, the following protective measures will be used. 

Permethrin: No aerial use within 200 feet and no ground use within 80 feet of water 

bodies or wetlands inhabited by this species. Chlorpyrifos: No ground use within 100 

feet or aerial use within 350 feet of water bodies or wetlands inhabited by this species. 

Buffers apply to all of the habitat area and at least 1⁄2 mile upstream from the habitat in 

any contributing channel, tributary or spring run. The buffer zones should also be 

applied to 300 feet downstream from species habitat. 

Tern, least 

(Interior) 

Sterna 

antillarum E 

Permethrin: No aerial use within 1⁄4 mile and no ground use within 300 feet around 

nesting colonies. Chlorpyrifos: No ground use within 300 feet or aerial use within 1⁄4 

mile around nesting colonies. Aerial applications should be made parallel to a colony 

and its aerial buffer zone. 

The following buffers will be applied at the edge of the closest water body (stream, 

river, lake, reservoir, etc.) to the colony, but apply only to lakes and reservoirs less 
Protection measures for endangered & threatened species – 2007 B-3 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

than 100 surface-acres or streams and rivers that are less than 300 feet wide. These 

buffers are: for both chlorpyrifos and permethrin, no ground treatments within 80 feet 

and no aerial treatment within 200 feet from water’s edge for 2 miles up- and 

downstream from the colony’s closest point to the water body. 

Vireo, blackcapped Vireo atricapilla E 

To protect the black-capped vireo and its prey from aerial and ground applications of 

permethrin and chlorpyrifos, the following protective measures will be used. 

Permethrin: No ground use within 30 feet and no aerial use within 150 feet of species 

habitat. Chlorpyrifos: No ground use within 60 feet or aerial use within 300 feet of 

species habitat. 

REPTILES 

Rattlesnake, 

New 

Mexican 

ridge-nosed 

Crotalus willardi 

obscurus T,CH NE – Excluded by habitat. 

Tortoise, 

desert 

Gopherus 

agassizii T,CH 

To protect the desert tortoise from aerial and ground application of permethrin and 

chlorpyrifos, a 600-foot ground buffer and a 1⁄4-mile aerial buffer will be used at the 

edge of habitat of the desert tortoise. These protection measures will be implemented 

if information indicates that desert tortoises are occupying habitat adjacent to a cotton 

field. 

AMPHIBIANS 

Frog, 

Chiricahua 

leopard 

Rana 

chiricahuensis T 

To protect the Chiricahua leopard frog from aerial and ground application of 

permethrin and chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will 

be used when these insecticides are applied above the high water line of Chiricahua 

leopard frog habitat. These insecticides should not be applied below the high water 

line of Chiricahua leopard frog habitat. 

Salamander, 

Sonora tiger 

Ambystoma 

tigrinum 

stebbinsi E 

To protect the Sonora tiger salamander from aerial and ground application of 

permethrin and chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will 

be used at the edge of known occupied habitat (including stock ponds or watering 

tanks) of the Sonora tiger salamander. Buffer zones will be applied to land adjacent 

to water bodies and wetlands that serve as species habitat. Buffers will be used for 

(1) all of the habitat area and (2) at least 1 mile upstream and 300 feet downstream 

from the habitat area in any contributing channel, tributary, or spring run. 

FISH 

Catfish, 

Yaqui Ictalurus pricei T,CH 

To protect the Yaqui catfish from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1/2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Chub, 

bonytail Gila elegans E,CH 

To protect the bonytail chub from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Chub, Gila Gila intermedia E,CH 

To protect the Gila chub from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Chub, 

humpback Gila cypha E, CH To protect the humpback chub from aerial and ground application of permethrin and chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 
Protection measures for endangered & threatened species – 2007 B-4 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Chub, Virgin 

River 

Gila seminuda 

(=robusta) E, CH 

To protect the Virgin River chub from aerial and ground application of permethrin 

and chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at 

the edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area 

and (2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Chub, Yaqui Gila purpurea E,CH 

To protect the Yaqui chub from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Gambusia, 

Big Bend Gambusia gaigei E NE – Excluded by habitat. 

Gambusia, 

Pecos 

Gambusia 

nobilis E 

To protect the Pecos gambusia from ground and aerial application of chlorpyrifos and 

permethrin in Jeff Davis, Reeves, and Pecos Counties in Texas, the following 

protection measures will be used. No ground treatments within 400 feet and no aerial 

treatment within 1⁄8 mile of the spring outlet for Phantom Lake Spring (Jeff Davis 

County), the spring outlets for San Solomon Spring, Giffin Spring, and East Sandia 

Spring (Reeves County), or the area covered by Leon Creek, Diamond Y Draw, 

Diamond Y Spring, Gonzales Spring, and their associated wetlands or spring runs up 

to 2 miles east of the crossing of States Highway 18 over Diamond Y Draw (Pecos 

County). 

Minnow, 

Devils River Dionda diaboli T 

To protect the Devils River minnow from aerial and ground application of permethrin 

and chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at 

the edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area 

and (2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Minnow, 

loach Tiaroga cobitis T,CH 

To protect the loach minnow from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Minnow, 

Rio Grande 

silvery 

Hybognathus 

amarus E,CH 

To protect the Rio Grande silvery minnow from aerial and ground application of 

permethrin and chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer 

will be used at the edge of aquatic habitat. Buffer zones should be used for (1) all of 

the habitat area and (2) at least 1⁄2 mile upstream and 300 feet downstream from the 

habitat area in any contributing channel, tributary, or spring run. 

Pupfish, 

Comanche 

Springs 

Cyprinodon 

elegans E 

To protect the Comanche Springs pupfish from ground and aerial application of 

chlorpyrifos and permethrin, the following protection measures will be used. No 

ground treatments within 400 feet and no aerial treatment within 1⁄8 mile of the spring 

outlet for Phantom Lake Spring (Jeff Davis County) or the spring outlets for San 

Solomon Spring, Giffin Spring, and East Sandia Spring (Reeves County). 

Pupfish, 

desert 

Cyprinodon 

macularius E,CH 

To protect the desert pupfish from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Pupfish, 

Leon 

Cyprinodon 

bovinus E,CH NE – Excluded by habitat. 
Protection measures for endangered & threatened species – 2007 B-5 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

Springs 

Shiner, 

beautiful 

Cyprinella 

formosa T,CH 

To protect the beautiful shiner from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Spikedace Meda fulgida T,CH 

To protect the spikedace from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Sucker, 

razorback 

Xyrauchen 

texanus E,CH 

To protect the razorback sucker from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Topminnow, 

Gila (incl. 

Yaqui) 

Poeciliopsis 

occidentalis E 

To protect the Gila topminnow from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Trout, 

Apache 

Oncorhynchus 

apache T 

To protect the Apache trout from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Trout, Gila Oncorhynchus 

gilae 

Downlisted 

from E to 

T 

To protect the Gila trout from aerial and ground application of permethrin and 

chlorpyrifos, a 400-foot ground buffer and a 1⁄8-mile aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

Woundfin Plagopterus 

argentissimus 

E, CH 

EXPN 

To protect the woundfin from aerial and ground application of permethrin and 

chlorpyrifos, a 100-foot ground buffer and a 350-foot aerial buffer will be used at the 

edge of aquatic habitat. Buffer zones should be used for (1) all of the habitat area and 

(2) at least 1⁄2 mile upstream and 300 feet downstream from the habitat area in any 

contributing channel, tributary, or spring run. 

SNAILS 

Snail, Pecos 

assiminea Assiminea pecos E,CH 

To protect the Pecos assiminea snail from ground and aerial application of 

chlorpyrifos and permethrin in Reeves and Pecos Counties in Texas, the following 

protection measures will be used. No ground treatments within 400 feet and no aerial 

treatment within 1⁄8 mile of the spring outlets for San Solomon Spring, Giffin Spring, 

and East Sandia Spring (Reeves County), or the area covered by Leon Creek, 

Diamond Y Draw, Diamond Y Spring, Gonzales Spring, and their associated 

wetlands or spring runs up to 2 miles east of the crossing of States Highway 18 over 

Diamond Y Draw (Pecos County). 

PLANTS 

Arizona 

agave Agave arizonica Delisted None – delisted taxon 

Arizona Purshia E To protect pollinators of the Arizona cliff-rose from aerial and ground application of 
Protection measures for endangered & threatened species – 2007 B-6 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

cliff-rose (=Cowania) 

subintegra 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(late March to early May) if the application is made in early dawn (no later than one 

hour after sunrise) or early evening (6 p.m. or later). For applications made in cotton 

fields outside the flowering period, applications may be applied beyond the 80-foot 

ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Bunched 

cory cactus 

Coryphantha 

ramillosa T NE – Excluded by habitat. 

Canelo Hills 

ladies’ 

tresses 

Spiranthes 

delitescens E 

To protect pollinators of the Canelo Hills ladies’-tresses from aerial and ground 

application of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer 

and a 1⁄4-mile aerial buffer from occupied species habitat will be used during the 

flowering period (summer) if the application is made in early dawn (no later than one 

hour after sunrise) or early evening (6 p.m. or later). For applications made in cotton 

fields outside the flowering period, applications may be applied beyond the 80-foot 

ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Chisos 

Mountain 

hedgehog 

cactus 

Echinocereus 

chisoensis var. 

chisoensis 

T 

To protect pollinators of Chisos Mountain hedgehog cactus from aerial and ground 

application of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer 

and a 1⁄4-mile aerial buffer from occupied species habitat will be used during the 

flowering period March to July) if the application is made in early dawn (no later than 

one hour after sunrise) or early evening (6 p.m. or later). For applications made in 

cotton fields outside the flowering period, applications may be applied beyond the 

80-foot ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Cochise 

pincushion 

cactus 

Coryphantha 

robbinsorum T 

To protect pollinators of Cochise pincushion cactus from aerial and ground 

application of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer 

and a 1⁄4-mile aerial buffer from occupied species habitat will be used during the 

flowering period March to May) if the application is made in early dawn (no later 

than one hour after sunrise) or early evening (6 p.m. or later). For applications made 

in cotton fields outside the flowering period, applications may be applied beyond the 

80-foot ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Davis’ green 

pitaya 

Echinocereus 

viridiflorus var. 

davisii 

E 

To protect pollinators of Davis’ green pitaya from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(February to May) if the application is made in early dawn (no later than one hour 

after sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Gypsum 

wildbuckwheat 

Eriogonum 

gypsophilum T,CH NE – Excluded by habitat, no insect pollination 

Hinckley 

oak 

Quercus 

hinckleyi T NE – No insect pollination 

Holmgren 

milk-vetch 

Astragalus 

holmgreniorum 

E, CH (CH 

new as of 

12/06) 

To protect pollinators of Holmgren milk-vetch from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(April to May) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Huachuca 

water-umbel 

Lilaeopsis 

schaffneriana 

var. recurva 

E,CH 

To protect pollinators of the Huachuca water-umbel from aerial and ground 

application of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer 

and a 1⁄4-mile aerial buffer from occupied species habitat will be used during the 
Protection measures for endangered & threatened species – 2007 B-7 

COMMON 

NAME 

SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

flowering period (summer) if the application is made in early dawn (no later than one 

hour after sunrise) or early evening (6 p.m. or later). For applications made in cotton 

fields outside the flowering period, applications may be applied beyond the 80-foot 

ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Jones 

cycladenia 

Cycladenia 

jonesii(=humilis) T NE – No insect pollination 

Kearney’s 

blue-star 

Amsonia 

kearneyana E 

To protect pollinators of Kearney’s blue-star from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(April to June) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Little Aguja 

pondweed 

Potamogeton 

clystocarpus E 

To protect pollinators of Little Aguja pondweed from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(March to April) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Lloyd’s 

Mariposa 

cactus 

Echinomastus 

mariposensis T 

To protect pollinators of Lloyd’s mariposa cactus from aerial and ground application 

of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(February to July) if the application is made in early dawn (no later than one hour 

after sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day 

Nellie cory 

cactus 

Coryphantha 

minima E 

To protect pollinators of Nellie cory cactus from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(March to June) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Nichol’s 

Turk’s head 

cactus 

Echinocactus 

horizonthalonius 

var. nicholii

E 

To protect pollinators of Nichol’s Turk’s head cactus from aerial and ground 

application of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer 

and a 1⁄4-mile aerial buffer from occupied species habitat will be used during the 

flowering period late April to mid-May) if the application is made in early dawn (no 

later than one hour after sunrise) or early evening (6 p.m. or later). For applications 

made in cotton fields outside the flowering period, applications may be applied 

beyond the 80-foot ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Pecos (= 

puzzle) 

sunflower 

Helianthus 

paradoxus T 

To protect pollinators of Pecos sunflower from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(August to May) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 
Pr

COMMO

NAME 

otection measures for endangered & threatened species – 2007 B-8 

N SCIENTIFIC 

NAME STATUS PROTECTION MEASURES 

Pima 

pineapple 

cactus 

Coryphantha 

scheeri var. 

robustispina 

E 

To protect pollinators of Pima pineapple cactus from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(June to August) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Siler 

pincushion 

cactus 

Pediocactus 

(=Echinocactus, 

=Utahia) sileri 

T 

To protect pollinators of Siler pincushion cactus from aerial and ground application of 

permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(spring) if the application is made in early dawn (no later than one hour after sunrise) 

or early evening (6 p.m. or later). For applications made in cotton fields outside the 

flowering period, applications may be applied beyond the 80-foot ground or 1⁄4-mile 

aerial buffer zone at any time during the day. 

Sneed 

pincushion 

cactus 

Coryphantha 

sneedii var. 

sneedii 

E NE – Excluded by habitat 

Terlingua 

Creek cat’seye 

Cryptantha 

crassipes E 

To protect pollinators of Terlingua Creek cat’s-eye from aerial and ground application 

of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(March to May) if the application is made in early dawn (no later than one hour after 

sunrise) or early evening (6 p.m. or later). For applications made in cotton fields 

outside the flowering period, applications may be applied beyond the 80-foot ground 

or 1⁄4-mile aerial buffer zone at any time during the day. 

Texas 

snowbells Styrax texanus E NE – Excluded by habitat 

Tobusch 

fishhook 

cactus 

Ancistrocactus 

tobuschii E 

To protect pollinators of Tobusch fishhook cactus from aerial and ground application 

of permethrin and chlorpyrifos in cotton fields, an 80-foot ground buffer and a 1⁄4-mile 

aerial buffer from occupied species habitat will be used during the flowering period 

(late January to early April) if the application is made in early dawn (no later than one 

hour after sunrise) or early evening (6 p.m. or later). For applications made in cotton 

fields outside the flowering period, applications may be applied beyond the 80-foot 

ground or 1⁄4-mile aerial buffer zone at any time during the day. 

Todsen’s 

pennyroyal 

Hedeoma 

todsenii E,CH NE – Excluded by habitat 
2007 Endangered and Threatened Species Site Reporting Form - Pink Bollworm Eradication 

Use additional copies as needed. Prior to the start of applications of pesticides, return the completed form to: Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04.6, Riverdale, MD 20737 Work unit/District/Zone/Program:_____________________________________________Sta

Species Field Number(s) Acres GPS Coordinates Distance to Field Comments 
 C-1 

ENVIRONMENTAL MONITORING SUPPLIES CHECKLIST

SUPPLIES TO BRING EACH TIME YOU GO TO A SAMPLING SITE

Monitoring plan/SOP’s 

Obtain from 

ECT Thermometer 

Field log notebook Ice chest/wet or blue ice 

Obtain 

locally 

Compass Baby wipes 

Wind gauge 2060 monitoring forms 

Indelible marker Packing/strapping tape 

A.R.S.E. (Run-off Sampling) Dye Cards

Plexiglas cover Oil sensitive dye cards 

8"x 8" mesh screen Water sensitive dye cards 

Tent pegs/nails 5' bamboo poles/stakes 

Funnels attached to caps Paper/binder clips 

500 ml bottles Tacks 

4" PVC pipe, 14" long 4" x 4" plastic bags 

Post hole digger 12" x 12" plastic bags 

Pea gravel Tweezers/forceps 

Large rocks/bricks disposable gloves 

Bamboo pole/flagging tape Water Samples

collapsible cubitainer Dissolved oxygen kit 

Sodium sulfate (small vials) collapsible cubitainer 

pH paper/pH meter Sodium sulfate (small vials) 

Sulfuric acid (squeeze bottle) pH paper/pH meter 

Styrofoam ‘coffin’ Sulfuric acid (squeeze bottle) 

Vegetation/Fish Samples Sediment Samples

Pruning sheers/scissors Dredge tied to strong rope

Aluminum foil envelopes 3 gallon galvanized pail

Strapping tape Hand trowel

3" mesh screen

Aluminum foil envelopes
 C-2 

Soil Samples Swab/Wipe Samples

Soil core sampler 3” x 3” sterile cotton pads 

with resealable plastic bag 

3 gallon galvanized pail Metric ruler 

Hand trowel Pencil 

3" mesh screen Disposable gloves 

Aluminum foil envelopes Isopropyl alcohol Obtain 

locally

Baby wipes 

Neat (Pure) Chemical Formulations Miscellaneous Supplies

Amber glass bottle Labels 

Parafilm Styrofoam coolers/mailers 

Small mailing tubes Freezer 

Obtain 

locally

Cat litter/packing material Dry ice 

Obtain 

locally 

Disposable pipette Resealable plastic bags: 

Pipetting bulb 4" x 4" 

Disposable gloves 6" x 6" 

Protective eyewear 8" x 8" 

 12" x 12" 

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

To order supplies, indicate the quantity of each items needed. Fax a copy of this form to ANPCL at 

228-822-3209 or 228-822-3137. If fax machines are not working, leave a message with the ANPCL supplies 

manager at 228-822-3106. Please realize that it may be difficult to completely fill order for large quantities of 

materials. 

Note: This is not an exhaustive supply list...items that are not listed here may be available through ANPCL.